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Entities supervised by the CSSF: it’s time to register on e-Desk for the 2019 AML/CFT risk assessment survey

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02 December 2019

The CSSF has announced that entities under its supervision will have to complete the next annual AML/CFT risk assessment survey using the e-Desk platform. The period to complete the survey will open on 3 February 2020 for all entities and close after 4 weeks for the banking sector and 6 weeks for other supervised entities.
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On 27 November 2019, the CSSF issued a press release 19/57 to inform entities it supervises that the annual survey for 2019 collecting standardised key information on (i) the ML/FT risks to which supervised entities are exposed and (ii) the implementation of related risk mitigation and financial sanctions measures will need to be completed online via e-Desk.

The CSSF points out that only a few persons can complete the survey on behalf of the supervised entity:

  • a member of the management body of the entity and preferably the AML/CFT Compliance Officer who is esponsible for AML/CFT compliance (referred to as RR in the latest CSSF FAQ on the persons involved in AML/CFT for funds and investment fund managers, please see our e-alert here); or
  • another employee of the entity, subject to proper delegation via e-Desk and with ultimate responsibility for the said ML/CFT Compliance Officer.

Since access to e-Desk for such purposes will require the creation of an account with LuxTrust authentication, the CSSF recommends that the relevant member of the management body and, to the extent necessary, the delegate employee create an account as soon as possible or, in other words, ensure that they have a LuxTrust device (i.e. a token, smartcard, signing stick, LuxTrust scan or LuxTrust mobile). This is particularly relevant for non-resident persons who probably do not have a LuxTrust device and will have to order one. The CSSF stresses that the survey will have to be completed exclusively via e-Desk within a defined period: within 4 weeks for the banking sector and within 6 weeks for other supervised entities as from 3 February 2020. For further information on the creation of an e-Desk account, please see the e-Desk User Guide.

Other than these technical details, which may impair, if they are not anticipated, completion of the survey in due time, the content of the 2019 AML/CFT risk assessment survey remains generally unchanged compared with the previous year.

If you would like to discuss any of the issues raised in this article, please speak to your usual contact at Allen & Overy or one of the contacts listed at the end of this publication. Entities supervised by the CSSF: it’s time to register on e-Desk for the 2019 AML/CFT risk assessment survey

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